To make a purchase through the Site, we require you to supply us with your first and last name, home or other physical address, including your street name and address and name of your city or town, your telephone number or other "real world" personal contact information. If you supply us with your personal contact information, you may later access it, update it, modify it and delete any inaccuracies. Please note, we generally keep a copy of the previous personal contact information for our records. We aim to keep our information about you as accurate as possible. If you would like to review or change the details you have supplied us with, you may do so at any time by accessing your account through the My Account link located at the top of each page on the Site. You may also choose simply not to provide your personal contact information at the point of collection; however, you will not be able to purchase products through the Site.

We use the information that we collect to operate and maintain our websites and to respond to your questions and concerns. The legal basis is art. 6(1)(f) of the EU General Data Protection Regulation (GDPR).

To register for an account through the Site, we require you to supply us with your email address, or other information needed to contact you online. If you supply us with your email address, you may later access it, update it, modify it, and delete any inaccuracies by accessing your account through the My Account link located at the top of each page on the Site. Please note, we generally keep a copy of your previous email address(es) for our records. You may also choose simply not to provide us with your email address; however, you will not be able to purchase products through the Site. We use this information to complete, support, and analyze your purchases from us, to facilitate and improve your use of the Site, to communicate with you, and to comply with any requirements of law. We also use this information to respond to any questions you might have and to provide you with information about specials offered through the Site. This information may be disclosed to our staff and to third parties involved in the completion of your transaction, the delivery of your order, or the analysis and support of your use of the Site. This information, including your email address(es), may be shared with our affiliated companies, under common ownership, who will also use it consistent with this Privacy Policy. HaloCigs and our affiliated companies may also combine this information with other information to provide and improve our products, services, content, and advertising. HaloCigs and our affiliated companies do not sell and will not divulge your email address to third parties other than as specified in this Privacy and Security Policy without your permission unless we are legally entitled to obliged to do so (for example, if required to do so by Court order or for the purposes of prevention of fraud or other crime).

If you do not want to be on HaloCigs’ or our affiliated company’s mailing lists, you can opt out any time by updating your preferences in your account or by unsubscribing to any of the emails through the UNSUBSCRIBE link.

When you purchase an item through the Site, you are required to select a method of payment. For credit cards, we reveal only the last four digits of your credit card numbers when confirming an order. We transmit your entire credit card number to the appropriate credit card company in an encrypted format during order processing. We keep your credit card information on file in an encrypted format, taking precaution to maintain physical, electronic and procedural safeguards over your credit card information. We use this information to complete, support and analyze your purchases, to facilitate and improve your use of the Site, to communicate with you, for internal purposes and to comply with any requirements of law. This information may be disclosed to our staff and to third parties involved in the completion of your transaction, the delivery of your order or the analysis and support of your use of the Site. We do not sell and will not divulge your personal contact information to third parties other than as specified in this Privacy and Security Policy without your permission unless we are legally entitled or obliged to do so (for example, if required to do so by Court order or for the purposes of prevention of fraud or other crime).

We may display personal testimonials of satisfied customers on our Site or social media in addition to other endorsements only with your consent. With your consent, we may post your testimonial along with your name. If you wish to update or delete your testimonial, you can contact us at communications@nicopure.com.

We may collect information actively generated by the purchase of a product or service, such as a payment method. We use this information to process your order and analyze and support your use of the Site. This information may be disclosed only to our staff and to third parties involved in the completion of your transaction, the delivery of your order or the analysis and support of your use of the Site. We do not sell and will not divulge your purchase information to third parties other than as specified in this Privacy and Security Policy without your permission unless we are legally entitled or obliged to do so (for example, if required to do so by Court order or for the purposes of prevention of fraud or other crime).

As you browse our Site, we may gather navigational and click stream data that shows what pages are visited and how long various features are used. This information will not reveal your identity or be linked to you personally. We use this information to complete, support and analyze your purchases from us; to facilitate and improve your use of the Site; to comply with any requirements of law; to serve, or have a third party serve specialized or relevant advertising content and/or recommendations to you on the Site or on a third party’s website; for internal purposes; and to determine any commissions due our Affiliates. This information may be disclosed only to our staff and to third parties involved in the completion of your transaction, the delivery of your order, and the analysis and support of your use of the Site. We may from time to time supply the owners or operators of third party sites from which it is possible to link to our Site with information relating to the number of users linking to our Site from their sites. You cannot be identified from this information.

We may disclose your information to our staff and to third parties involved in the completion of your transaction, the delivery of your order, and the analysis and support of your use of the Site. We reserve the right to disclose your personally identifiable information if necessary to protect our legal rights, if the information relates to actual or threatened harmful conduct, or we have good faith belief that such action is necessary to (1) conform to the requirements of law or comply with governmental orders, court orders, or legal process served on us or (2) to protect and defend our property or other rights, the users of the Site or the public. This includes exchanging information with other companies and organizations for fraud protection and credit risk protection. We might sell, assign or otherwise transfer such information in the course of corporate divestitures, mergers, acquisitions, bankruptcies, dissolutions, reorganizations, liquidations, similar transactions or proceedings involving all or a portion of the company. Your information such as customer names and email addresses, and other user information may be among the items sold or otherwise transferred in these types of transactions. You will be notified via email and/or a prominent notice on our site of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.

Cookies are very tiny text files that are stored on your computer when you visit certain web pages that record your preferences. We use cookies to provide you with the best level of service by keeping track of what you have in your shopping cart, remembering you when you return to our store and using them to help us show you advertisements which are relevant to your interests. They cannot harm your computer and they do not contain any personal or private information. You must accept cookies to shop through the Site. You can erase or block cookies from your computer if you want to (your help screen or manual should tell you how to do this), but the Site may not work correctly or at all if you set your browser not to accept cookies.

We offer secure web pages to collect certain kinds of user information and we store certain kinds of data in encrypted form. We follow reasonable technical and management practices to help protect the confidentiality, security and integrity of data stored on our system. While no computer system is completely secure, we believe the measures implemented by our Site reduce the likelihood of security problems to a level appropriate to the type of data involved. Our servers use Secure Sockets Layer (SSL) and encryption technology that works with Netscape Navigator, Microsoft Internet Explorer, Firefox, Safari, and AOL's browser, with the objective that only we can read a customer's personal information. We employ physical, electronic and procedural safeguards in connection with the collection, storage and disclosure of any personal contact information. We comply with the EU GDPR framework as set forth by the European Union regarding the collection, use, and retention of personal data from European Union member countries. We adhere to the requirements of notice, choice, onward transfer, security, data integrity, access and enforcement.

We generally keep user data on our server or in our archives for as long as we reasonably need it (for instance for taxation or insurance purposes or in case orders may give rise to claims). We may alter this practice according to changing requirements. For example, we may delete some data if needed to free up storage space. We may keep other data for longer periods if the law requires it. In addition, information posted in a public forum could stay in the public domain indefinitely, and you should consult that forum’s separate privacy policy.

This Site may contain links to third party websites. We are not responsible for the privacy practices or the content of such websites even if they are accessed using links from our Site. Your use of these third-party websites is entirely at your own risk and we recommend that you check the privacy and security policy of each site you visit. When you click on a third-party link, you are essentially taken to a third party’s website. We make no representation or warranty as to the effectiveness, quality, legitimacy or data protections of any third-party website.

It is very important to us that we provide you with the highest level of service. In order to help us do this, from time to time we may send you details of products and services which we think may be of interest to you. We may send you marketing communications with your consent. If at any time you do not wish to receive these details and wish to unsubscribe from marketing communications, you may do so by accessing your account through the My Account link located at the top of each page on the Site.

We may provide you the opportunity to participate in contests or surveys on our site. If you participate, we will request certain personally identifiable information from you. Participation in these surveys or contests is completely voluntary. Therefore, you have a choice whether or not to disclose this information. The requested information typically includes contact information (name, address, email address, and/or phone number). We may request other information, in our sole discretion, which we consider important to the administration of the survey or contest.

We use this information to notify contest winners and award prizes, monitor site traffic, personalize the site, and send participants an email newsletter. We may also use this information for publicity or marketing purposes. We may publish this information in our sole discretion. The rules applicable to any individual survey or contest will be published prior to the collection of any personally identifiable information and you agree to such use by submitting any information.

We may also use a third-party service provider to conduct these surveys or contests. However, that company is prohibited from using our users’ personally identifiable information for any other purpose. We will not share the personally identifiable information you provide through a contest or survey with other third parties unless we give you prior notice and choice.

For current customers, you can review, correct, update or delete inaccuracies to the information about you that we have on file by logging into your account to update your password and billing information. Alternately, you can contact us directly at 888-425-6649. We will acknowledge your request within seventy-two (72) hours and handle it promptly. Data protection law gives you a range of rights in connection with our processing of your personal data. In this regard, you have the right to request that we rectify or delete the personal data or restrict the processing of your personal data. Furthermore, you have the right to object against the processing based on our legitimate interests as a legal basis. We are required to assess and act on your request. Additionally, you also have the right to data portability if it should become relevant. You have a right to lodge a complaint with your local supervisory authority in your EU country of residence. If you have any questions about this Privacy Policy or your rights under data protection law, you can contact us at 888-425-6649.

In compliance with the EU-US and Swiss-US Privacy Shield Principles, we commit to resolve complaints about your privacy and our collection or use of your personal information. EU and Swiss Data Subjects with questions or concerns about the use of their Personal Data should contact us at 888-425-6649. If your question or concern cannot be satisfied through this process, we will refer unresolved privacy complaints under the EU-US and Swiss-US Privacy Shield Frameworks to BBB EU Privacy Shield, an independent dispute resolution mechanism operated in the United States by the Council of Better Business Bureaus. If you do not receive timely acknowledgement of your complaint, or if your complaint is not satisfactorily addressed by us, EU and Swiss Individuals and Data Subjects should go to http://bbb.org/EU-privacy-shield/for-eu-consumers/ for more information or to file a complaint. The services of the BBB EU Privacy Shield will be provided at no cost to you. Finally, as a last resort and in limited situations, EU and Swiss Individuals and Data Subjects may seek redress from the Privacy Shield Panel — a binding arbitration mechanism.

It is our policy to provide notifications, whether such notifications are required by law or are for marketing or other business-related purposes, to you via email, written or hard copy notice, or through conspicuous posting of such notice on the Service, as determined by us in our sole discretion. We reserve the right to determine the form and means of providing notifications to you, provided that you may opt out of certain means of notification as described in this Privacy Policy.

All changes to this Privacy Policy are effective when they are posted on this page. When we change the policy in a material manner, we will let you know via email and/or a prominent notice on our site, prior to the change becoming effective and update the ‘effective date’ at the bottom of this page.

Our Site includes social media features, such as the Facebook button and other widgets, that run on our Site. These features may collect your IP address and which page you are visiting on our site and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our Site. Your interactions with these features are governed by the privacy policy of the organization providing it.

California Consumer Privacy Act

The California Consumer Privacy Act of 2018 (“CCPA”) provides verified California residents additional rights to know, delete and opt out, and requires businesses collecting or disclosing personal information to provide notices and means to exercise these rights.

Notice of Collection

In the last twelve (12) months we have collected personal information in the following categories. The categories and examples provided in the chart below are defined in the CCPA. Not all information is collected about all individuals and it is possible that all examples of that category of Personal Information were not in fact collected but this reflects our belief that to the best of our knowledge that some of that information may have been collected about consumers. In response to a verified consumer request for categories of information collected, we will investigate and provide an individualized response to the consumer.

 

Category	Examples
Identifiers	A name, email address, IP Address, online identifier, or account name.
Personal information categories listed in the California Customer Records Statute (Cal. Civ. Code § 1798.80)	A name, billing address, shipping address, telephone number, credit card number, debit card number, or any other financial information. Some personal information included in this category may overlap with other categories.
Protected classification characteristics under California or federal law	Age, veteran or military status.
Commercial information	Records of products purchased, obtained, or considered or other purchasing or consuming histories or tendencies.
Internet or similar network activity	Browsing history, search history, information on a consumer's interaction with a website, application or advertisement.
Geolocation data	Physical location.
Inferences drawn from personal information.	Profile reflecting a person's interests, preferences and favorites.

Sources of Personal Information

We obtain the categories of Personal Information listed above from the following categories:

• Directly from you. For example, during account registrations or during purchases.
• Indirectly from you. For example, from observing actions on our Site.
• From third parties. For example, third party service providers who provide services or information for us.

Use and Disclosure of Personal Information

Under the CCPA “sale” means:

"(A) Selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer's personal information by the business to a third party for valuable consideration; or (B) sharing orally, in writing, or by electronic or other means, a consumer's personal information with a third party, whether for valuable consideration or for no consideration, for the third party's commercial purposes." Accordingly, we do not sell our consumers personal information.

Use of Personal Information for Business Purposes or Commercial Purposes

We may use or disclose Personal Information we collect for business or commercial purposes (as defined under the CCPA), which may include the following examples. The examples provided are illustrative and not intended to be comprehensive.

• Security. For example, preventing fraud, detecting security breaches, and maintaining the safety and security of our Site.
• Functionality debugging/error repair. For example, identifying and repairing errors in the functionality of the Site.
• Communications. For example, sending you offers, promotions, or notifying you about changes to our policies.
• Internal research and development. For example, research, analysis, and product development to improve our products.
• Performing Services. For example, creating, maintaining, and securing your account, processing your purchases, transactions, and payments.
• Quality and Safety Maintenance. For example, improving or enhancing our products or Site and verifying the quality and safety of our Site.

Disclosing Personal Information to Third Parties

We may disclose your personal information to the following categories for a business purpose or commercial purpose, as those are defined in the CCPA:

• Service providers
• Government regulators
• Advertisers and other third parties with whom we have business relationships

CCPA Privacy Rights

Under the CCPA, California residents have the specific rights regarding their Personal Information as described below.

(a) Right to Know about Personal Information Collected or “Sold”

You have the right to request that we disclose certain information to you about our collection and use of your Personal Information over the past 12 months. After we receive and confirm your verifiable consumer request, we will disclose to you within the time required by the CCPA, the relevant information which may include:

• The categories of Personal Information we collected about you.
• The categories of sources for the Personal Information we collected about you.
• Our business or commercial purpose for collecting or selling that Personal Information.
• The specific pieces of Personal Information we collected about you.
• If we sold your Personal Information, or disclosed your Personal Information for a business purpose, two separate lists disclosing:

1. sales, identifying the Personal Information categories that each category of recipient purchased; and

2. disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained.

(b) Right to Delete

You have the right to request we delete any of your Personal Information we collected from you and retained, subject to exceptions, including if we need the Personal Information for a reason related to our business, such as

• Providing goods to you;
• Detecting and resolving issues related to security or functionality;
• Complying with legal obligations;
• Conducting research in public interest;
• Exercising free speech or ensuring another’s exercise of free speech; or
• Using the information for internal purposes that a consumer might reasonably expect.

After we receive and confirm a verifiable consumer request, we will delete the Personal Information from our records within the time required by the CCPA, unless an exception applies.

(c) Right to Non-Discrimination

You have the right not to receive discriminatory treatment for the exercise of any of your CCPA rights.

(d) Right to Opt-Out

You have the right to opt-out of the “sale” of your personal information. We do not currently sell personal information. If in the future that changes you will be notified and given the option to opt-out.

Exercising Your Rights

To exercise your CCPA the rights, please submit a verifiable consumer request to us by emailing privacy@halocigs.com.com or calling 888-425-6649. You may only make a verifiable consumer request for access twice within a 12-month period. The verifiable consumer request must provide sufficient information that allows us to reasonably verify you are the person whom we collected personal information on or an authorized representative, which may include: providing your email and phone verification, known customer information, and/or account sign-up authentication or other information needed to verify your identity. We cannot respond to the request or provide Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. We use good faith efforts to respond to a verifiable consumer request within forty-five (45) days after its receipt. If we need more time, we will notify you of the need for a forty-five (45) day extension.

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Pursuant to California Civil Code, we do not share your personal information with third parties for those parties’ direct marketing use unless you elect that we do so.

If you have a privacy question about the Site, or about the Privacy and Security Policy, please email us, or contact us at 888-425-6649. If you are a California resident, California Civil Code permits you to request information regarding the disclosure of your personal information by us to third parties for the third parties’ direct marketing purposes. To make such a request, please email us, or contact us at 888-425-6649.